Anti-bribery Policy

Policy Overview

Purpose

The purpose of this policy is to convey to all employees and interested parties Oxford Analytica’s unequivocal stance towards the eradication of bribery, the rules that we apply in that regard, and our commitment to ensuring that the company conducts its business in a fair, professional and legal manner.

Definition

Bribery is, in the conduct of the Company’s business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence. Oxford Analytica prohibits any form of bribery. We require compliance with the highest ethical standards and anti-bribery laws applicable from everyone connected with our business.

Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by Oxford Analytica employees or by third parties acting for or on behalf of Oxford Analytica.

Scope

This policy applies to all employees of Oxford Analytica, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement.

We will seek to apply this policy to all suppliers; contractors working on our behalf and/or supplying services to us.

Further definitions

Definitions of bribery and corruption:

Corruption is the misuse of office or power for private gain.

Bribery is a form of corruption which means in the course of business: giving or receiving money, gifts, meals, entertainment or anything else of value; as an inducement to a person to do something which is dishonest or illegal.

Offences

It is a criminal offence to:

offer a bribe

accept a bribe

bribe a foreign official

as a commercial organisation, to fail to prevent a bribe.

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay a fine.

Policy

It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact the Director of Operations or a Managing Director so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this the Director of Operations or a Managing Director. You may be asked to give a written account of events.

Appropriate checks may be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

The Company will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.

Oxford Analytica takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc.

Gifts and hospitality

We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.

Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.

No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from a Managing Director or the Director of Operations, except where the value of hospitality given is within the expense guidelines of the firm which is then permitted without written approval.

No gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf from any party in connection with our business without receiving prior written approval from a Managing Director or the Director of Operations, except where the cumulative value of such hospitality from the same source over a one-month period is less than 100 USD, which may then be accepted without written approval.

Written approval must always be sought for gifts given or received.

A record must be made of every instance in which gifts or hospitality are given or received whether or not it required written approval, and submitted quarterly for review. For hospitality given, expense claims are an adequate record provided they specify the name of the individual to whom it is given along with their organisation.

Where Managing Directors require written approval, they should seek it from the Global Managing Director or the Director of Operations. Where the Global Managing Director requires approval, s/he should seek it from the Director of Operations or the Chairman of the Board.

As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.